ITAT Cuttack Quashes 271D, 271E Penalties for Lack of Recorded Satisfaction

Maleckunnel Philip Varghese Vs DCIT (ITAT Cuttack)

No Satisfaction, No Penalty under section 271D & 271E of Income Tax Act, 1961 – ITAT Cuttack follows SC in Jai Laxmi Rice Mills 

Cuttack ITAT quashed penalties levied u/s 271D & 271E on the ground that no satisfaction was recorded by the AO in the assessment order for initiating such penalty proceedings.

Assessee challenged the penalty on three primary grounds  (i) absence of satisfaction recorded in assessment order; (ii) penalties barred by limitation; & (iii) no cas

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